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Medical Surveillance as Part of Safety & Health Program, Especially for Diacetyl / DAPORS

Although this post is in context of Diacetyl/ DAPORS /Popcorn Lung, it is important to remember that an appropriate medical surveillance program plays an important part in ensuring employee protections in other circumstances as well. The specifics of the medical surveillance program will depend on the particular issues encountered at a given facility. In the case of food flavoring manufacturers, for example, monitoring employees for certain health conditions such as what will seem like occupational asthma, but may actually be the development of a rare lung disease called bronchiolitis obliterans (more commonly known as ‘popcorn lung’).

Employers implementing such a program need to remember that this is sort of a last line of defense in terms of protecting employees from health hazards. Implementing engineering controls to design the hazard out of the work process, proper personal protective equipment, effective training are some of the other risk mitigation methods that can help prevent the possibility of illnesses from developing in the first place. More on those methodologies are/will be available in other posts.

OSHA has launched a National Emphasis Program (NEP) on Food Flavorings Containing Diacetyl. One of the things the Compliance Officer will be looking for is a sound medical surveillance program.

According to the OSHA NEP Directive on Food Flavorings Containing Diacetyl, Medical Surveillance Program(s) might want to consider:

A medical screening program can help employers identify employees experiencing adverse health effects from exposure to hazardous food flavoring chemicals. Spirometry, or pulmonary function testing (PFT), measures the breathing capacity of the lungs and is the best available test for early detection of decreasing or abnormal lung function amongexposed employees.For starters, it is recommended that employers:

  • Perform a baseline spirometry test for all newly-hired employees and ask eachemployee to complete a health questionnaire before starting work in areas wherethere is exposure.

  • Perform a medical evaluation (i.e. health questionnaire) and spirometry every sixmonths for all employees exposed. A qualified physician with expertise inoccupational lung disease can make additional recommendations regarding thenature and frequency of medical examinations and spirometry based on employeeexposures specific to operations in your facility.


Prometrix Consulting, with a staff of former OSHA officials, offers expert consulting and training services to help clients ensure compliance with complex workplace safety and health requirements.

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